RightHear™ Privacy Policy.

Introduction

Welcome to RightHear, an online service that helps blind, visually impaired and people with orientation disabilities, orient themselves at venues in outdoor surroundings and in which the Service is deployed (the “Service”).

This Privacy Policy (the “Policy”) explains our privacy practices for the Service we offer through our mobile app (the “App”). It describes how we collect information, use it and share it and the rights and options available to you with respect to that information.

Providing us the information is a choice you make. We appreciate that and thank you for making this choice. You are not legally obligated to provide us with this information, but we do need it to allow you to use the Services.

This policy is combined into our Terms of Use (the “Terms”), and is a part of them.

In short…

The following key points of the Privacy Policy are only brought for your convenience. They do not substitute the full Policy.

1. Information we collect or access. The App detects your mobile device’s geolocation, both when the App is active and inactive, but we do not store this data. We use third party analytics tools to collect information about your use of the App. We also collect information about your mobile device, including its model, operating system and unique device identifiers.

2. Using the information we collect. We use the information we collect to operate the Service, improve and customize them and develop new services.

3. Access to Information. You may request to access your information, or have us update, correct or delete such information, if the law provides you those rights and to the extent that it is practicable.

4. Aggregated information. We may use the information we collect from you to create de-identified, statistical or aggregated information, and make it available to others for any purpose.

5. Retention. We retain the information for as long as we deem necessary for the purpose it was first obtained.

6. Security. We implement measures to reduce the risks of damage and unauthorized access or use of information, but they do not provide absolute information security.

7. Children privacy. We do not knowingly or intentionally collect information about children who are under 13 years of age.

8. Changes to the Policy. We may change this Policy, by putting you on notice of such changes. Your continued use of the App after the changes take effect indicates your acceptance of the amended Policy.

How it works?

Our Service offers orientation information about nearby places in outdoor surroundings, based on your location. Through the App you can navigate to a desired location, personalize your use of the App by uploading places such as your home or work (“Your Places”), and use the App to guide you in a specified direction.

The App uses your mobile smartphone’s Text-to-Speech capability to provide you orientation information. You can listen to this information with your device’s speakers, or with the use of earphones.

You can also use the App to venture in accessible venues in which the Service is deployed (“Venues”). These Venues have specially designated accessibility spots scattered throughout the building. The App helps you orient yourself at the venue based on the communications that the App receives from those accessibility spots.

If the Venue operates an assistance helpdesk and has configured the Service to provide access to this helpdesk, then you may use the App to call the Venue’s representative for assistance. In that case, the App will place the call through your device’s telephone. Telephone charges may apply in accordance with your mobile subscription plan at your cellular provider. IN CASE OF AN EMERGENCY, CALL YOUR LOCAL EMERGENCY DISPATCH CENTER IMMEDIATELY – DO NOT USE THE APP’S ASSISTANCE FEATURE.

Information we collect or access

Geolocation. The App detects your mobile device’s geolocation in order to provide you orientation information. The App detects your mobile device’s geolocation also when the App is inactive, in order to notify you when you approach a Venue in which the Service is deployed. We do not, however, store this geolocation information.

Content. You may upload content on to the App such as Your Places and your voice recordings of Your Places (“Content”). Such Content may be publicly viewable if you choose to share it. Use caution and common sense when uploading Content and sharing it on to the App. Do not share any Content that may contain, or be indicative of, any sensitive personal information about yourself or third parties.

Inquiries. If you contact us for questions or complaints, we will collect the information related to your inquiry. This may include your name, email address, telephone number and other contact information, depending on the nature of your inquiry.

Children’s Privacy

We do not knowingly or intentionally collect information about children who are under 13 years of age.

Use of collected information

Your consent serves as the legal basis for processing your information. You may withdraw consent at any time, without affecting the lawfulness of data processing we carried out based on your consent before such withdrawal.

We may use the information we collect for the following purposes:

Operating the Services and providing their features and functionalities;

Improving and customizing the Services and developing new services;

Collecting statistical and aggregated information about users’ experience within the Services;

Providing you with support, handling complaints and contacting you when we believe it is necessary;

Enforcing the Terms and this Policy and preventing misuse of the Services;

Complying with any applicable law and assisting law enforcement agencies and competent authorities, if we believe it is necessary or justified; and

Taking any action in any case of dispute involving you, with respect or in relation to the App.

Sharing information collected

We may share the information outlined in this Policy, with others, in any of the following instances:

With our contractors and service providers, for data analysis and processing, bug reporting and handling, and in order to operate, maintain and enhance the Service;

If you have breached the Terms, abused your rights to use the Services, or violated any applicable law. The information we collect may be shared with competent authorities and with any third party, if we believe it is necessary or justified;

If the operation of the Services is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition);

Providing you with support, handling complaints and contacting you when we believe it is necessary;

We may share the information we collect with our corporate group entities, but their use of such information must comply with the Policy.

Accessing, updating or deleting your personal information

In accordance with applicable law and operational limitations, you may ask to access the information about you that is stored in our systems, or have us update, correct or delete such information. You are also entitled to ask to transfer your data to another provider (‘data portability’ right), in accordance with the law. If you wish to exercise any of these rights, contact us at: [email protected].

Aggregated information

We may use the information we collect, as outlined above, to compile anonymized or aggregated information. We may share, sell or otherwise communicate and make available such anonymized or aggregated information to any other third party, at our sole discretion. However, we will not share information that can be reasonably used to identify you without your consent.

Transfer of data outside your territory

We may store and process information in the EU and in other countries such as the United States. We may also process information using cloud services. The laws in those other countries may provide a lesser degree of data protection than the laws of your own country. You agree to the transfer of your information to such other countries for the purpose of processing as described in this Policy, including through cloud services.

Information Security

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. These measures do not provide absolute information security. Therefore, it is not guaranteed, and you cannot expect that the Services will be immune from information security risks.

CALIFORNIA RESIDENTS

The following disclosure is made pursuant to California Online Privacy Act (CA Civil Code § 22575): When you use our Service, other parties, such as Google, may collect personally identifiable information about your activities over time and across different websites or online services.

Data retention

We retain information for as long as we deem necessary for the purposes set forth above. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.

Changes to this Privacy Policy

We may change this Policy. We will provide you notice of such changes through the App’s interface. Your continued use of the Service constitutes your consent to the amended Policy. If you do not consent to the amended Policy, we may terminate your account and block your access to, and use of, the Service.